Representation by Dover District Council (Dover District Council )
- Date submitted
- 2 October 2018
- Submitted by
- Local authorities
Thank you for notifying Dover District Council (DDC) of the acceptance of the application for Development Consent Order regarding the proposed upgrade and re-opening of Manston Airport. The District Council wishes to register as an interested party and has set out below its position in respect of the project:
Principle of the Proposed Development
DDC welcomes and offers its full support to RiverOak Strategic Partners’ (RSP) proposal to re-open Manston Airport as an operational freight-focused airport and recognises the positive contribution it would make to the regeneration of the East Kent economy, as well as the UK’s aviation economy.
The proposed development is supportive of the following motion passed by the District Council in July 2014 in relation to the former Manston Airport site:
“The Council supports the campaign to retain Manston as an operational airport, recognising the role and place it can have in the UK aviation industry, making better use of regional capacity in accordance with the views of the South East Local Enterprise Partnership, while making a significant contribution as on the strategic priorities for regeneration of the East Kent area.”
Maximising the potential of East Kent’s location as a gateway to continental Europe and its fast links to London, as well as a significant economic sub-region is essential in providing a strong platform for growth and responding effectively to the implications of a post-Brexit environment.
The location of the proposed development site to Discovery Park and Kent Count Council’s (KCC) proposed Thanet Parkway Railway Station at Cliffsend, combined with commitments in investing in key infrastructure (e.g. strategic network improvements), will offer the opportunity to further enhance domestic and international connectivity and attract inward investment to East Kent. DDC wishes to work closely with the Applicant in maximising the economic potential of the proposed development for the Dover District, its businesses and residents, in particular to help support innovation, productivity and skills development across the wider East Kent sub-region.
Technical Matters:
Economy - The District Council supports the Applicant’s commitment to work closely with local councils to help to promote job opportunities for local people and wishes to build on this to ensure that the development of skills is supported to help deliver East Kent priorities.
Further clarification is sought regarding the scope of work anticipated to ensure that the economic benefits of the proposed development for East Kent can be realised.
With regard to the forecast generation of 2,655 jobs and 30,000 jobs by years 2 and 20 respectively, DDC notes the submission of the Employment Land and Housing Technical Report (Document 7.2: Planning Statement) and would welcome the opportunity to work closely with the Applicant and the relevant neighbouring authorities in assessing the implications of projected employment growth on development requirements for East Kent.
Traffic & Transportation - DDC relies on the expertise of KCC – as Local Highway Authority – in assessing the impacts of the proposed development on the strategic highway network and the identification of associated mitigation measures.
Landscape - The District Council concurs with the proposed sensitivity assessment for Landscape Character Areas within its administrative boundary as set out in the Environmental Statement (Document 5.2-2).
With regard to the height of structures proposed as part of the development proposal (e.g. new Air Traffic Control facilities at 27m, cargo facilities at 20m and aircraft recycling hangars at 23m), DDC wishes to further engage with the Applicant as the DCO process advances to assess the landscape and visual impact of the proposals and alternatives from receptors located in the Dover District and to identify any mitigation measures, where required.
To date, there has been no further correspondence on this matter beyond the formal consultation process however the District Council is currently in the process of negotiating a Planning Performance Agreement with the Applicant to enable this work to be undertaken.
Noise - With regard to the Noise Mitigation Plan (Document 2.4, page 1), the proposed development site and intended flight paths indicate that the greatest impact from noise would be on areas located within the Thanet and Canterbury administrative boundaries. Given the proximity of the proposed development site to the northern boundary of the Dover District administrative area, in particular the area around Plucks Gutter, East Stourmouth and West Stourmouth, it is recommended that reference is made to noise impact on areas located within the Dover District.
As part of the formal consultation process, the District Council submitted its comments in relation to the identification of adverse noise effects in 5 locations including West Stourmouth (located in the Dover District) where noise would increase to a point where there would be a perceived change in quality of life. Specifically, questions were raised in relation to the exclusion of West Stourmouth from baseline monitoring. Whilst, the Applicant has stated in its Consultation Report (Document 6.1) that undertaking long term noise measurements at all receptors would be considered impractical, DDC considers that more detailed noise measurements are required for the West Stourmouth and would welcome further engagement with the Applicant on this matter.
Additionally, it is noted that properties in the Dover District fall outside of the noise contours as referred to in paragraphs 2.4 and 2.5 of the Noise Mitigation Plan (Document 2.4) concerning noise insulation funding. Specifically, this relates to ‘…residential properties with habitable rooms within the 63dB LAeq (16 hour) day time contour…’ and ‘…residential properties with bedrooms falling within the 55dB LAeq (8 hour) contour…’ and the provision of ‘…reasonable levels of noise insulation and ventilation for schools and community buildings within the 60dB LAeq (16 hour) daytime contour…’
It should be noted that these levels are greater than those given with respect to acoustic insulation under the Heathrow Expansion consultation in January 2018 which refers to 60dB LAeq (16 hour) contours for an inner zone and 57dB LAeq (16 hour) contours for an outer zone. In addition, the Civil Aviation Authority’s recent findings on Aircraft Noise and Annoyance (February 2018) makes reference to UK policy in relation to an ‘annoyance threshold’ and highlights 57dB LAeq (16 hour) as marking the approximate onset of significant community annoyance. This was reaffirmed in the Department for Transport’s Aviation Policy Framework (2013).
Therefore, DDC recommends that the daytime noise contour of 60dB LAeq (16 hour) used for schools and community buildings is also used as the daytime noise contour qualification for noise insulation.
Ecology - DDC relies on the expertise of KCC, Natural England and the Environment Agency in assessing the ecological impacts of the proposed development on environmentally designated sites.
Heritage - DDC relies on the expertise of Historic England and KCC Heritage Conservation to assess the potential impact of the proposed development on the historic environment.
Planning Performance Agreement
The District Council is currently in the process of preparing and negotiating a Planning Performance Agreement (PPA) with RSP to ensure effective joint working and optimal outputs throughout the DCO process. With regard to maximising a functional effective approach, DDC would commend a joint PPA with our neighbouring authorities.
I trust that you find all of the above comments useful and the District Council very much looks forward to continue to be fully involved in the plans by RSP to reopen Manston as a fully operational airport.
Please do not hesitate to contact me if you require any further clarifications at this point.
Yours sincerely,
K Morris Leader of the Council